36jil Privacy Policy

1 Introduction

36jil is committed to protecting the privacy and personal data of all players who use our platform. We understand that trust is the foundation of any relationship between a player and an online gaming platform — and that trust begins with being transparent about how we handle your information.

This Policy applies to all personal data collected through the 36jil website, mobile platform, customer support channels, and any other service operated by 36jil. It covers data collected directly from you, data generated through your use of the platform, and data received from third parties in connection with your account.

This Policy should be read alongside 36jil's Terms & Conditions and Responsible Gaming Policy, both of which are available on the 36jil platform. Together, these documents form the complete framework governing your relationship with 36jil.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, 36jil is the data controller responsible for the personal data collected through the platform.

As data controller, 36jil determines the purposes and means of processing your personal data. 36jil has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with applicable data protection laws and this Policy. You may contact the DPO at any time using the contact details provided in Section 15 of this Policy.

3 Personal Data We Collect

36jil collects personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the platform. The categories of personal data we collect include:

Sensitive Personal Information: In certain circumstances, 36jil may collect sensitive personal information as defined under the Data Privacy Act, including government-issued identification numbers (such as SSS, UMID, or PhilSys ID numbers) for KYC purposes. Such data is processed with heightened security measures and only to the extent required by law or regulation.

Data You Provide Voluntarily: Some data is collected only when you choose to provide it, such as when you contact customer support, participate in promotions, or complete optional profile fields. You are not obligated to provide this data, but failure to do so may limit your access to certain features or services.

4 How We Use Your Personal Data

36jil uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your 36jil account, including verifying your identity and eligibility to use the platform;
• Service Delivery: To provide access to games, process bets, calculate and pay out winnings, and deliver all other services offered through the 36jil platform;
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods;
• KYC & Compliance: To verify your identity, age, and eligibility in accordance with anti-money laundering (AML) regulations and responsible gaming obligations;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform;
• Responsible Gaming: To monitor gaming behavior, identify signs of problem gambling, and administer responsible gaming tools such as deposit limits and self-exclusion;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Marketing & Promotions: To send you information about 36jil promotions, bonuses, and new features, where you have consented to receive such communications;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality and user experience of the 36jil platform;
• Legal Obligations: To comply with applicable Philippine laws, regulations, court orders, and regulatory directives.

5 Legal Basis for Processing

36jil processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its implementing rules:

• Contractual Necessity: Processing is necessary to perform the contract between you and 36jil (i.e., the Terms & Conditions), including account management, payment processing, and service delivery;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and regulatory reporting;
• Legitimate Interests: Processing is necessary for 36jil's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and interests;
• Consent: For certain processing activities — such as marketing communications and the use of non-essential cookies — 36jil relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

36jil does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and InstaPay, for the purpose of processing your deposits and withdrawals;
• KYC & Identity Verification Providers: Third-party identity verification services used to confirm your identity and age in compliance with regulatory requirements;
• IT & Platform Service Providers: Cloud hosting, data storage, cybersecurity, and analytics providers who process data on 36jil's behalf under strict data processing agreements;
• Game Content Providers: Licensed game studios and software providers whose games are available on the 36jil platform, to the extent necessary for game operation and dispute resolution;
• Regulatory & Law Enforcement Authorities: Philippine government agencies, regulatory bodies, courts, and law enforcement authorities, where disclosure is required by law or a valid legal order;
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

In all cases where 36jil shares personal data with third-party service providers, we require those providers to implement appropriate technical and organizational security measures and to process data only in accordance with 36jil's instructions and applicable law.

7 Cookies & Tracking Technologies

36jil uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the platform to function correctly. These cookies enable core features such as account login, session management, and security. They cannot be disabled without affecting platform functionality;
• Performance & Analytics Cookies: Used to collect anonymized information about how players use the 36jil platform, helping us identify areas for improvement and optimize the user experience;
• Functional Cookies: Allow the platform to remember your preferences (such as language settings and display options) to provide a more personalized experience;
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of 36jil's marketing campaigns. These cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 36jil platform. For more information on managing cookies in popular browsers, refer to your browser's help documentation.

8 Data Retention

36jil retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with 36jil, plus a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory directive or legal proceeding;
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal purposes;
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of compliance.

When personal data is no longer required, 36jil will securely delete or anonymize it in accordance with our data disposal procedures.

9 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 36jil:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as described in this Policy;
• Right of Access: The right to request a copy of the personal data 36jil holds about you, along with information about how it is being used;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by 36jil;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 36jil's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

10 Data Security

36jil implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 36jil platform;
• Encryption of sensitive data at rest, including financial information and government ID data;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

11 Children's Privacy

The 36jil platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gambling regulations. 36jil does not knowingly collect personal data from individuals under the age of 21.

If 36jil becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account with 36jil, please contact our support team immediately so that we can investigate and take appropriate action.

12 International Data Transfers

36jil primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international game content studios.

Where personal data is transferred outside the Philippines, 36jil ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses that meet the standards required by the National Privacy Commission. 36jil will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards.

13 Third-Party Links

The 36jil platform may contain links to third-party websites or services. This Privacy Policy applies solely to the 36jil platform and does not cover the privacy practices of any third-party websites or services. 36jil is not responsible for the content, privacy policies, or data practices of any third-party sites.

We encourage you to review the privacy policies of any third-party websites you visit before providing any personal information to those sites.

14 Updates to This Privacy Policy

36jil reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, 36jil will notify registered account holders via the email address on file and/or by displaying a prominent notice on the platform.

The date of the most recent revision is indicated at the top of this page. Your continued use of the 36jil platform following the effective date of any update constitutes your acceptance of the revised Policy. We recommend reviewing this Policy periodically to stay informed of how 36jil protects your personal data.

15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 36jil, please contact us through the following channels:

• Data Protection Officer Email: [email protected]
• Live Chat: Available 24/7 through the 36jil platform
• Support Hours: 24 hours a day, 7 days a week, Philippine Standard Time
• Service Area: Serving players across Manila, Cebu, Davao, Quezon City, Makati, and all of the Philippines

For data subject rights requests (access, rectification, erasure, portability), please include your full name, registered email address, and a description of your request. 36jil will verify your identity before processing any data subject request to protect against unauthorized access to personal data.